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Iesse RP 5 Ir--PB96128103 n ;, 11\11111111111 \\11111111 1I111I1 . j =----- ICSSC Guidance on Implementing Executive Order 12941 on Seismic Safety of Existing Federally Owned or Leased Buildings Diana Todd and Ann Bieniawski, editors October 1995 Building and Fire Research Laboratory National Institute of Standards and Technology Gaithersburg, :MD 20899 u.s. National Technical Inlormalion Service Springfield, Virginia 2216'1 )' '--------- - u.s. Department of Commerce Ronald H. Brown, Secretary Technology Administration Mary L. Good, Under Secretary for Technology National Institute of Standards and Technology Arati A. Prabhakar, Director Prepared for: Federal Emergency Management Agency Mitigation Directorate Washington, DC 20472

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Page 1: Ir--PB96128103 Iesse RP 5...Iesse RP 5 Ir--PB96128103 n;, 11\11111111111 \\11111111 1I111I1 . ~j ''-----::NI=-=-=S=T==IR=---=:57~3~4=----- ICSSC Guidance on Implementing Executive

Iesse RP 5

Ir--PB96128103 n;, 11\11111111111 \\11111111 1I111I1 .~ j''------::NI=-=-=S=T==IR=---=:57~3~4=-----

ICSSC Guidance on Implementing ExecutiveOrder 12941 on Seismic Safety of ExistingFederally Owned or Leased Buildings

Diana Todd and Ann Bieniawski, editors

October 1995Building and Fire Research LaboratoryNational Institute of Standards and TechnologyGaithersburg, :MD 20899

u.s. O~~;~~~n~~~~:~:mercetD§National Technical Inlormalion Service

Springfield, Virginia 2216'1 )''--------- -

u.s. Department of CommerceRonald H. Brown, SecretaryTechnology AdministrationMary L. Good, Under Secretary for TechnologyNational Institute of Standards and TechnologyArati A. Prabhakar, Director

Prepared for:Federal EmergencyManagement AgencyMitigation DirectorateWashington, DC 20472

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NIST-114 U.S. DEPARTMENT OF COMMERCE - -.-.

tREV.6-931 NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGYEiAJU

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N616'R5 § DI~2;1ADMAN 4.09 '.

MANUSCRIPT REVIEW AND APPROVAL PUBLfcATION REPORT NUMBER CATEGORY CODEIt/a .INSTRUCTIONS: ATTACH ORIGINAL OF THIS FORM TO ONE (1) COPY OF MANUSCRIPT AND SEND TO PUBLICATION DATE INUMBER PRINTED PAGESTHE SECRETARY, APPROPRIATE EDITORIAL REVIEW BOARD

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ICSSC Guidance on Implementing Executive Order 12941 on Seismic Safety of Existing Federally Owned or Leased Buildings

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NISTIGAITHERSBURG

Todd, D.; Bieniawski, A. ~NISTIBOULDER

to---JILAIBOULDER

LABORATORY AND DIVISION NAMES IFIRST NIST AUTHOR ONLY)

Building and Fire Research Laboratory, Structures Division, D. ToddSPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (STREET, CITY, STATE, ZIP)

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PROPOSED FOR NON·NIST PUBLICATION (CITE FULLY) U U.S. U FOREIGN PUBLISHING MEDIUMr--

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ABSTRACT IA 2000-CHARACTER OR LESS FACTUAL SUMMARY OF MOST SIGNIFICANT INFORMATION. IF DOCUMENT INCLUDES A SIGNIFICANT BIBLIOGRAPHY ORLITERATURE SURVEY, CITE IT HERE. SPELL OUT ACRONYMS ON FIRST REFERENCE.) (CONTINUE ON SEPARATE PAGE, IF NECESSARY.)

In this guidance document, the Interagency Committee on Seismic Safety in Construction (ICSSC) recommends appropriate approachesfor Federal departments and agencies to use in implementing the inventorying and cost estimating requirements of Executive Order12941. -TIle'inverifonescand cost estimates"are'to besuoinitfed to FEMA by December 1, 1998> The JCSSC recommends that allFederally-owned buildings be included in an electronic inventory database of specified format. Buildings are to be identified as eitherexempt or non-exempt from the seismic standards adopted by the order. All exceptionally high risk buildings are to be seismicallyevaluated, and estimates of the cost of their rehabilitation developed. Additionally, agencies are to perform seismic evaluations on arepresentative sample of their non-high-risk, non-exempt buildings,_aJLd use this information to estimated the vulnerability of thatpopulation and the cost of achieving adequate seismic safety.~, =,~~ .:

-

KEY WORDS (MAXIMUM OF 9; 28 CHARACTERS AND SPACES EACH; SEPARATE WITH SEMICOLONS; ALPHABETIC ORDER; CAPITALIZE ONl Y PROPER NAMES)

Building technology; buildings; cost estimate; earthquake; Executive Order 12941; existing buildings; inventory; rehabilitation;seismic evaluation; seismic rehabilitation; seismic safety

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ACKNOWLEDGEMENTS

The Interagency Committee on Seismic Safety in Construction (JCSSC) Subcommittee 1,Standards for New and Existing Buildings, developed this document for fonnal ballot review andapproval by the full ICSSC. The following people contributed to the development of thisdocument:

ICSSC Members:

H. S. Lew, chainnanKharaiti AbrolCharles AndersonKrishna BangaJames BinkleyJack BryndaOilda del CastilloHarish ChanderTom ChappellJoseph CorlissRichard CutsingerMike DavisterDon DentonDon EvickNathaniel FosterJoe Galetovic .Charles GutberletLucian GuthrieBruce HallWalt HaysDon HealdJames HillSam HodgesLarry HultengrenBill JacksPaul JohnsonHoward KassTom KearnsJeff KimballJim LafrenzDoreen Christian LarocheShi-Chi LiuRobert MadisonRita MartinTom MoranUgo MorelliTom MyersTom Nelson

National Institute of Standards and TechnologyVeterans AffairsDept. ofInteriorVeterans AffairsUS Postal ServiceDept. of InteriorUS Information AgencyDept. of EnergyUS Dept. of AgricultureHealth and Human ServicesTennessee Valley AuthorityDept. of EnergyDept. of EnergyUS Postal ServiceTennessee Valley AuthorityDept. of InteriorUS Anny Corps of EngineersUS Anny Corps of EngineersGeneral Services AdministrationUS Geological SurveyUS Dept. of AgricultureDept. of EnergyUS Dept. of AgricultureDept. of StateTennessee Valley AuthorityDept. of InteriorNational Aeronautics and Space AdministrationFederal Bureau of PrisonsDept. of EnergyUS Air ForceUS Dept. of AgricultureNational Science FoundationDept. of TransportationDept. of TransportationEnvironmental Protection AgencyFederal Emergency Management AgencySmithsonian InstituteDept. of Energy

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Howard NickersonBrian OlsonDavid PerkinsU PorterFidel RodriguezEufracio SabayErda! SafakJohn ScalziMike SchillingHerbert SchneiderSubir SenCharles SmithBob SteinLance SwanhorstSteve SweeneyTerry WongMarshall Wright

ICSSC Technical Secretariat:

Diana Todd, NISTAnn Bieniawski., NIST

US NavyDept. of InteriorUS Geological SurveyDept. of InteriorUS Army Corps of EngineersDept. of InteriorUS Geological SurveyNational Science FoundationDept. of StateDept. of InteriorDept. of EnergyDept. of InteriorDept. of TransportationEnvironmental Protection AgencyUS Army Corps of EngineersDept. of InteriorDept. of Interior

Structural Engineering Consultants:

Chris Poland, Degenkolb EngineersWilliam T. Holmes, Rutherford & Chekene

NlST Consultants

Keith Eberhardt, Engineering StatisticsTerry King, Computer Databases

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PREFACE

On December 1, 1994, the President signed Executive Order 12941, Seismic Safety ofExistingFederally Owned or Leased Buildings. The order adopted minimum technical standards for allfuture seismic safety evaluation and rehabilitation projects for Federally owned and leasedbuildings. These standards, Standards ofSeismic Safety for Rtisting Federally Owned orLeasedBuildings, are referred to in this document as ICSSC RP4. In addition, the order called for allagencies and departments owning or leasing buildings to develop, by December 1, 1998, aseismic inventory of their owned and leased buildings, and to estimate the costs of mitigatingunacceptable seismic risks in that inventory.

The inventory and cost infonnation is being collected in order to develop reliable infonnationupon which to build future public policy. At the time the order was signed, only limited dataon the vulnerability of the approximately half-million Federally-owned buildings existed. Thegovernment-wide seismic rehabilitation cost estimates that could be generated based on this datawere judged to be too uncertain to allow for reliable budget planning.

The order directs the Interagency Committee on Seismic Safety in Construction (ICSSC) to issueguidance on how to develop the inventory and cost estimate. Thirty Federal departments andagencies with an interest in seismic safety participate iri the ICSSC. A major role of the ICSSCis to encourage the adoption of consistent and effective seismic safety practices by all entitiesof the Executive Branch of the Federal government. This is accomplished in part by developingand issuing Recommended Practices. A Recommended Practice (lCSSe RP document) must beapproved by at least two thirds of the member departments and agencies before it is issued.

This document, IeSSe RP5, presents the inventorying and cost estimating guidance called forin Executive Order 12941. A supplemental document, How-To Suggestions for ImplementingRtecutive Order 12941 on Seismic Safety of Existing Federal Buildings, A Handbook, to bepublished in December 1995, gives examples of how to put this guidance into practice.

Each agency's inventory and cost estimate is to be forwarded to the Federal EmergencyManagement Agency (FEMA) by December 1, 1998. FEMA will use the data to examine thecosts and benefits of a wide variety of potential programs to upgrade the seismic safety ofexisting Federal buildings. The order directs FEMA to submit to Congress, by December 1,2000, a "comprehensive report on how to achieve an adequate level of seismic safety in federallyowned and leased buildings in an economically feasible manner. H It is hoped that this effort willlead to the adoption of a pro-active program of systematic upgrading of the seismic safety ofFederal buildings.

The Technical Secretariat of the IeSSe is maintained by the Building and Fire ResearchLaboratory at the National Institute of Standards and Technology (NIST). The TechnicalSecretariat publishes and distributes IeSSC publications. For additional copies of this or otherICSSe documents, write to:

Icsse Technical SecretariatNIST/Building and Fire Research LaboratoryBuilding 226, Room B158Gaithersburg, MD 20899

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IV

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ABSTRACT

In this guidance document, the Interagency Committee on Seismic Safety in Construction(ICSSC) recommends appropriate approaches for Federal departments and agencies to use inimplementing the inventorying and cost estimating requirements of Executive Order 12941. Theinventories and cost estimates are to be submitted to FEMA by December 1, 1998. The JCSSCrecommends that all Federally-owned buildings be included in an electronic inventory database

- of specified fonnat. Buildings are to be identified as either exempt or non-exempt from theseismic standards adopted by the order. All exceptionally high risk buildings are to beseismically evaluated, and estimates of the cost of their rehabilitation developed. Additionally,agencies are to perfonn seismic evaluations on a representative sample of their non-high-risk,non-exempt buildings, and use this infonnation to estimate the vulnerability of that populationand the cost of achieving adequate seismic safety.

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TABLE OF CONTENTS

ACKNOVVLEDGEMrnNTS 1

PREFACE ill

ABSTRACT " " v

1.0 GOAL AND PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11.1 Introduction '. . . . . . . . .. 11.2 The Recommended Program: Owned Buildings. . . . . . . . . . . . . . . . . .. 11.3 The Recommended Program: Leased Buildings . . . . . . . . . . . . . . . . . .. 21.4 Products to be Produced by Each Agency 21.5 Organization of the Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2

2.0 INVENTORY DATABASE 32.1 Relationship to Existing Real Property Inventories .. . . . . . . . . . . . . . .. 32.2 Scope and Screening of Inventory . . . . . . . . . . . . . . . . . . . . . . . . . .. 32.3 Required Inventory Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4

3.0 EVALUATION PLAN 93.1 Selection of Buildings for Evaluation . . . . . . . . . .. 9

3.1.1 Evaluate All Exceptionally High Risk Buildings 93.1.2 Evaluate a Representative Sample of Remaining Non-Exempt

Buildings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 93.1.3 Report Results from Previous Evaluations . . . . . . . . . . . . . . . . . 10

3.2 Performing Evaluations on Selected Buildings 103.2.1 Goal of Evaluation 113.2.2 DNR (Definitely Needing Rehabilitation) Buildings . . . .. 11

4.0 ESTIMATING COST OF REHABILITATION 134.1 Cost Estimates for Evaluated and Deficient Buildings 134.2 Cost Estimates for Non-Evaluated Buildings 13

5.0 REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15The reporting requirements are as follows.

5.1 Contents and format of the submission . . . . . .. . . . . . . . . . . . . . . . . . . . 155.1.1 Databases ; 155.1.2 Supporting written documentation 15

5.2 Corrections to Submitted Databases 16

6.0 REFERENCES 17

APPENDIX A 19

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ICSSC Guidance on Implementing Executive Order 12941on Seismic Safety of Existing Federally Owned or Leased Buildings

1.0 GOAL AND PROCESS

1.1 Introduction

On December 1, 1994, President Clinton signed Executive Order 12941, Seismic Safety ofExisting Federally Owned or Leased Buildings. (See Appendix A for a copy of the order).Executive Order 12941 is but one step in a longer term effort to meet one of the goalsestablished by Congress and the President in creating the National Earthquake Hazard ReductionProgram (NEHRP) and reaffIrmed in the reauthorization of that program in November 1990 byPublic Law 101-614: to reduce seismic risk in Federal buildings to acceptable levels in asystematic way. Questions remain about how much it will cost, how long it will take, and whatthe top priorities should be in any program developed to achieve this goal.

Section 2 of the order is designed to collect the information needed to resolve some of theoutstanding questions. Section 2 requires that all agencies and departments inventory theirowned and leased buildings and estimate the costs of achieving adequate seismic safety in thosebuildings. The results of the cost estimate, along with supporting documentation, are to besubmitted to the Director of the Federal Emergency Management Agency (FEMA) no later thanfour years after the signing of the order. Within six years of the signing of the order, or on orbefore December 1, 2000, FEMA is required to submit to Congress "a comprehensive reporton how to achieve an adequate level of seismic safety in federally owned and leased buildingsin an economically feasible manner." The report is to be developed in consultation with theInteragency Committee on Seismic Safety in Construction (ICSSC), making use of the inventorydata and cost estimates submitted by building-owning and -leasing agencies.

Section 2 of the order also requires the ICSSe, within one year, to provide guidance onimplementing certain portions of the Executive Order. This document provides that guidance.Detailed information on implementing the guidance in this document is included in a companiondocument to be published in December 1995, How-To Suggestions for Implementing ExecutiveOrder 12941 on Seismic Safety of Existing Federal Buildings, A Handbook [Bieniawski,publication pending], herein called the Handbook.

1.2 The Recommended Program: Owned Buildings

The collected information will be used to examine a wide variety of possible Federal seismicrehabilitation programs. Given the anticipated public-policy and budgetary implications of anyrecommended rehabilitation program, it is vital that the data upon which the recommendationis based be of high quality: reliable, accurate, and defensible. However, given that the Federalgovernment owns close to a half million buildings, it would be prohibitively costly to collectdetailed .seismic vulnerability information and rehabilitation cost estimates on the entirepopulation. The ICSSC therefore recommends that data based on seismic evaluations becollected on all high risk/high priority buildings and on a representative sample of lower

I

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risk/lower priority buildings, as detennined by the agency in both cases.

1.3 The Recommended Program: Leased Buildings

The Executive Order requires that agencies inventory their leased buildings as well as ownedbuildings, and to develop estimates of the cost of mitigating unacceptable risks. The seismicsafety standards adopted by the order, JeSSe RP4 [Jesse 1994], include a program forreducing the seismic risk in leased buildings. Under this program, existing leases may be heldwithout action until they expire, but no new leases or lease renewals can be made in seismicallyunacceptable space. This program is expected to reduce the unacceptable seismic risk in leasedbuildings in a systematic, low cost way. The JeSSe does not expect that a more pro-activeprogram will be recommended for leased buildings any time in the foreseeable future.

Therefore, the JeSSe recommends that for compliance with the Executive Order 12941requirement for an inventory of leased buildings, agencies submit the leased building inventorythat is prepared annually by the agency at the request of the General Services Administration tofulfill real property reporting requirements, or any current agency leased-property inventory.No additions or modifications of this database are deemed necessary. For compliance with theExecutive Order requirement for a cost estimate for reducing unacceptable risks in leasedbuildings, agencies are asked to estimate the cost impact of the JeSSe RP4 program forreducing risk in leased buildings and to report that cost in the supporting documentation that issubmitted to FEMA. Jf an agency plans to use a different approach to reducing risk in leasedbuildings, that program and an estimate of the costs of implementing the program should bedescribed in the supporting documentation submitted to FEMA. Further guidance on this topicis included in the Handbook.

1.4 Products to be Produced by Each Agency

The order requires each agency owning or leasing buildings to complete its inventory and costestimate, and submit the cost estimate and supporting documentation to the Director of FEMAby December 1, 1998. The JeSSe recommends that each agency submit two electronicdatabases, one for owned buildings and another for leased buildings, and a written report withsupporting documentation. Details on the content, development, and reporting fonnat of thedatabases and supporting documentation are included in this document and in the Handbook.

1.5 Organization of the Guidance

Section 2 of this document describes the seismic inventory database to be created for all ownedbuildings. Section 3 presents recommendations for selecting buildings for seismic evaluation.Technical guidance covering the actual engineering evaluation is included in JeSSe RP4. Theevaluations are to be used to determine the acceptability or unacceptability of seismic safety inselected owned buildings. Section 4 describes recommended cost estimating procedures to beused with buildings found to pose an unacceptable seismic risk. It also addresses estimating thecost of achieving acceptable seismic safety in those buildings which have not been evaluated.Section 5 outlines the reporting procedures to be used. More detailed descriptions of eachrecommendation, and suggested procedures for carrying out inventorying and cost estimatingtasks can be found in the related sections in the Handbook.

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2.0 INVENTORY DATABASE

The Interagency Committee on Seismic Safety in Construction (ICSSC) recommendation forcreating the owned-building inventory called for in the Executive Order is as follows.

2.1 Relationship to Existing Real Property Inventories

Most agencies annually submit an inventory of real property to the General ServicesAdministration (GSA). This Executive Order 12941 inventory guidance tries, as much aspossible, to use the same data that is collected by agencies to meet GSA inventory requirements,to minimize duplication of effort and maximize consistency of reporting across variousgovernment inventory projects. However, the seismic inventory called for by Executive Order12941 will require the collection of some types of information that are not included in the GSAinventory. Agencies need not add this information to the GSA-required report. The inventoryto be submitted to the Federal Emergency Management Agency (FEMA) is to be in the form ofan electronic database, using a generic electronic format. It will make use of data that may havebeen collected already by agencies to fulfill GSA requirements, but it will not requiremodification of annual reporting to GSA.

2.2 Scope and Screening of Inventory

All owned buildings are to be included in the inventory database. Each· building will beclassified as either exempt or non-exempt.

Exempt Buildings are those which meet the criteria for exemption given in Section 1.3in ICSSC RP4, reprinted below. The seismic risk in these buildings is expected to be verylow, such that seismic rehabilitation would not be necessary. Additionally, buildings maybe exempted if they will no longer be used by any branch of the Federal government infive years, because they are scheduled to be abandoned, demolished, sold, or otherwiseremoved from government service.

Non-Exempt Buildings are those which do not meet the criteria for exemption. The levelof seismic risk in these buildings is not immediately apparent; the fact that they are noteligible for exemption means that they cannot be readily identified as presenting very lowrisk.

In this guidance document, the process through which exempt buildings are identified is knownas "screening". Detailed suggestions for screening methods are given in the Handbook. ICSSCRP4 exemptions are as follows:

a. buildings classified for agricultural use, or intended only for incidental human occupancy,or occupied by persons for a total of less than 2 hours a day,

b. detached one- and two-family dwellings that are located in areas having a governingacceleration coefficient less than 0.15 (within the United States, where A. is less than 0.15as delineated on Map 4 of the 1991 NEHRP Recommended Provisions for the DevelopmentofSeismic Regulations for New Buildings), (note: Map 4 is identical in the 1991 and 1994editions of the NEHRP Recommended Provisions)

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c. special structures including, but not limited to: bridges, transmission towers, industrialtowers and equipment, piers and wharves, and hydraulic structures,

d. one-story buildings of steel light frame or wood construction with areas less than 280 m2

(3000 square feet),e. fully-rehabilitated buildings which comply with the ICSSC RP4 seismic safety standards

in all four compliance categories (structural, nonstructural, geologic/site hazards, andadjacency),

f. post-benchmark buildings as defined in Table 1 of ICSSC RP4 which also comply with thenonstructural, geologic/site, and adjacency compliance categories,

g. pre-benchmark buildings which have been shown by evaluation to be life-safe in all fourcompliance categories,

h. buildings constructed for the Federal government whose detailed design was done after thedate of the adoption of Executive Order 12699 (January 5, 1990) and that were designedand constructed in accordance with the ICSSC Guidelines and Procedures for Implementa­tion ofthe Executive Order on Seismic Safety ofNew Building Construction [ICSSC 1992],

1. leased buildings identified in Section 1.3.2 (of ICSSC RP4) as exempt, orJ. Federally permitted or regulated privately owned buildings on Federal land.

Agencies which elect to specify benchmark years for exemption which differ from those givenin ICSSC RP4 shall report the years selected and rationale for the decision in the supportingdocumentation. (See the Handbook for detailed guidance on identifying exempt buildings.)

For exempt buildings, only a minimal amount of information need be collected and reported.(See Section 2.3 and Table A.) Additional information must be collected for non-exemptbuildings.

2.3 Required Inventory Data

Each building in the electronic inventory database will fall into one of the following threecategories: 1) exempt, 2) non-exempt, not evaluated, and 3) non-exempt, evaluated. The typesof data to be reported for each of the three categories of buildings are given below and in TableA. Definition of terms used follows the lists of data categories.

For exempt buildings, the inventory data is to include:- a unique identifier- location by state and county- seismicity: high, moderate or low- total area in square meters- reason for exemption

For non-exempt, not evaluated buildings, the inventory data is to include:- all types of data required for exempt buildings (the reason for exemption should be

reported as "not exempt")- occupancy class- whether building is essential- whether building is historic

4

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- date of construction- model building type- number of stories

For non-exempt, evaluated buildings, the inventory data is to include:- all types of data required for non-exempt, not evaluated buildings

whether building is perceived to be exceptionally high riskevaluation procedure usedsoil typefoundation typeoutcome of the evaluation: OK or deficientif deficient, why deficient,if deficient, estimate of the cost of rehabilitationif deficient, source of cost estimate

Terms used above and in Table A which require definition are as follows. More detailedinformation on each. of the data categories, including codes to be used in reporting theinformation, are given in the Handbook.

Unique Identifier is whatever alpha-numeric designation the agency uses to track itsbuildings in its own real property inventory. It may be an address, a coded number, orsome other method of identifying a specific building in the database.

Seismicity levels are defined by the Map Areas given on Map 2 (Av, county-by-county) inthe 1994 NEHRP Recommended Provisions [ESSe, 1995]. (The Handbook provides a tableindicating seismicity levels by state and county. The Handbook also gives guidance onusing the contour maps from the NEHRP Recommended Provisions for determiningseismicity level, for those agencies that wish to make more fine distinctions than arepossible using a county-based map.) Seismicity must be reported for all buildings, exemptand non-exempt.

Low seismicityModerate seismicityHigh seismicity

Map Areas 1 & 2Map Areas 3 & 4Map Areas 5, 6, & 7

Occupancy Classes are to be the same as those used in creating the real-property inventoryfor annual submission to GSA. Occupancy class is to be reported for all non-exemptbuildings. The 12 occupancy classes are:

- offices - housing- hospitals - storage- prisons industrial- schools - service- post offices - research & development- other institutions - miscellaneous

GSA does not provide standard definitions for these occupancy classes. For purposes ofconsistency, agencies are urged to use the same definitions for this seismic inventorydatabase as their agency uses for the GSA inventory, i.e. a building that is reported as

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"service" in the GSA inventory should also be reported as "service" in the seismicinventory database.

Essential buildings are those which, in the judgement of the owning agency, require a levelof seismic resistance that is higher than life safety. (Life safety is the minimum level ofprotection required by IeSSe RP4. After an earthquake, an IeSSe RP4 "life-safe"building should not have caused any fatalities, but it may be so badly damaged that it isno longer functional or even salvageable.) Examples of buildings which may fall into theEssential category are:

- hospitals, fIre and police stations, communication and command centers and otherbuildings that must remain functional in order to respond to an earthquakeemergency;

- buildings which must remain operational after an earthquake to maintain criticalagency functions;

- buildings housing hazardous materials which, if released as a result of an earthquake,would create an unacceptable risk; and

- buildings housing vulnerable populations or extremely valuable contents.Buildings which do not require greater than life safety protection are to be categorized asOther. The Essential/Other distinction is to be made for all non-exempt buildings.

Historic buildings are those which are included on any local, regional, state, national, orother register of historic buildings. Ifa building is potentially qualifIed to be on a historicregister, but has not been actually listed, it is not to be deemed historic in this inventory.The Historic/Non-Historic distinction is to be made for all non-exempt buildings.

Model Building Types reported in this inventory are to be the 15 types identified in theFEMA 178 [BSse, 1992]. The Handbook reproduces the defInitions. Model building typeis to be reported for all non-exempt buildings.

Soil Types are to be categorized into one of the four soil categories identified in FEMA 178,which are reproduced in the Handbook.

Foundation Types are to be categorized into one of three types: shallow foundations (isolatedor continuous spread footings or mats); deep foundations (piles or piers); or other. Thesetypes are defined in more detail in the Handbook.

Similar buildings may be reported in the electronic database in groups, rather than as individualentries, if they meet the criteria given below. When buildings are reported in groups, thenumber of buildings included in the group and the total area in square meters for all buildingsin the group must be reported.

Exempt buildings may be reported in groups rather than individually if they have the followingcharacteristics in common:

- same occupancy class- same state, county and seismicity- same reason for exemption

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Non-exempt, not evaluated buildings may be reported in groups only if they have the followinginventory characteristics in common:

- all characteristics identified above for groups of exempt buildings, except for "reason forexemption"

- similar (+ 10%) size and number of stories- similar date of construction (+ 5 years)- same model building type- same classification in historic, essential, and exceptionally high risk categories

Non-exempt, evaluated buildings may be reported in groups only if they have the followinginventory characteristics in common:

- all characteristics identified above for groups of non-exempt, not evaluated buildings- same soil type- same foundation type

For groups of buildings sharing these characteristics, a representative building may be selectedfor evaluation rather than evaluating each building in the group individually. In these cases, thesame evaluation outcome, reason for deficiency (if any), and cost per square meter forrehabiliation are to be assumed for all buildings in the group.

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Table A - Required Inventory Data for Owned Buildings

1\\·· <\. .••..••.••••••..•..•••.•••••••••••..••••••..••.. •.•.••.....••••••.••••••.•••••••..•. . .•••••••••••••••••••••••••••. ).i)ii.•. ·.>·•• >:·.·.·/iiF: )···.· ··<····.}··:··.i··.t·,.· ·.·.. .: ..' ~r~f~!~~t·j·•••••••.•••~ •••••.••.••••~••..•••.•..•••.••.•.•.•..••.••.••••.1\< ...••.. :. .•.•.. ...•• :.:•...••«/ \\ ..• <\ .:.\ . EV8lU3tedi ) :;.~k~;~~t,':

Unique Identifier

Location - State & County

Seismicity - High, Moderate or Low

Area in square meters

Reason for exemption, or Wnot exemptW

Occupancy Class (by GSA categories)

Essential or Other

Historic or Non-Historic

Date of construction

Model Building Type

Number of Stories

Exceptionally High Risk or Other

Evaluation Procedure Used

Soil Type

Foundation Type

Outcome of Evaluation: OK or Deficient

For Deficient Only: Why Deficient

(2 fields)

(2 fields)

(2 fields)

xx

xxx

xx

xxxx

xxxx

x

x

xxxxx

xxxxxx

xxxxx

For Deficient Only: Estimated Costs of Rehab (4 fields)

For Deficient Only: Source of Cost Estimate

xx

NOTE: Each of the characteristics are to be reported in a single field in the electronic database,unless otherwise noted above. Details of reporting (electronic fonnat; number, orderand size of fields; codes for categories; etc.) are contained in the Handbook.

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3.0 EVALUAnON PLAN

The Interagency Committee on Seismic Safety in Construction (ICSSC) recommended plan forselecting buildings for evaluation, and for carrying out those evaluations, is as follows.

3.1 Selection of Buildings for Evaluation

3.1.1 Evaluate All Exceptionally High Risk Buildings

Standards of Seismic Safety for Existing Federally Owned or Leased Buildings (ICSSCRP4), adopted by the President in Executive Order 12941 for use in Federally owned andleased buildings, identifies several situations in which seismic evaluation and mitigationis required. (See Section 2.1 of JCSSC RP4.) One of these situations is "the building isdeemed by the agency to be an exceptionally high risk to occupants or the public at large."

The JCSSC strongly recommends that, as part of performing the inventory required byExecutive Order 12941, each department and agency thoroughly examine its building stockand identify those buildings which represent an "exceptionally high risk." Componentsof risk that should be considered in identifying exceptionally high risk buildings shouldinclude not only regional seismicity and structural system, but also building function,number of occupants, value of contents, criticality to mission (whether building is deemed"Essential"), and any other characteristic judged important to the agency. Agencies shoulddefine "exceptionally high risk" such that the buildings so identified are those which wouldbe labeled as top priority for seismic rehabilitation. It is expected that the FEMA reportto Congress will identify the "exceptionally high risk" buildings as high priority candidatesfor rehabilitation funding. The Handbook offers suggestions on how to use the datacollected for inventory purposes to identify exceptionally high risk buildings.

It is expected that about five to ten percent of each agency's buildings in regions of highseismicity will fall into this category, along with one-half to one percent of the buildingsin regions of moderate seismicity, and an extremely small percentage of the buildings inregions of low seismicity. Agencies with higher than average numbers of exemptions canexpect to find their numbers of exceptionally high risk buildings to be at the low end ofthe ranges described above.

Every building identified as posing an exceptionally high risk should be subjected to aseismic evaluation prior to the December 1, 1998 deadline. Results of evaluationsperformed prior to the signing of Executive Order 12941 need not be repeated, if theoriginal evaluation, in the judgement of the agency, was substantially equivalent to orexceeded the ICSSC RP4 minimum evaluation procedure.

3.1.2 Evaluate a Representative Sample of Remaining Non-Exempt Buildings

Of the remaining non-exempt buildings in regions of moderate and high seismicity,agencies are asked to evaluate a representative sample of buildings, considering height,size, occupancy, and model building type. Each agency is to identify specific categoriesof buildings most representative of its non-exempt population, and perform enough

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evaluations within each category to adequately represent the entire category. It is expectedthat evaluations of about one to two percent of the non-exempt buildings would providean adequately representative sample. Specific suggestions on identifying appropriatecategories and selecting a representative sample of buildings are included in the Handbook.

3.1.3 Report Results from Previous Evaluations

Buildings which were evaluated prior to the initiation of the Executive Order 12941inventory and cost estimating project (according to criteria substantially equivalent to theICSSC RP4 minimum evaluation procedure) are considered to have fulfilled the evaluationrequirements described in Section 3.2 of this Guidance. Such buildings should be treatedas follows:

a. Those buildings which were found to be seismically adequate should be treated asnon-exempt buildings with an evaluation outcome of "OK" and reported in thedatabase as described in Section 2.3 of this Guidance. No further action is requiredon these buildings.

b. Those buildings which were found to be deficient and which were rehabilitated tostandards deemed adequate by the agency, are to be categorized as exempt (as perSection 1 of Executive Order 12941) and treated in accordance with Section 2.2 ofthis Guidance.

c. Those buildings which were found to be deficient but which have not yet beenrehabilitated should be treated as non-exempt buildings with an evaluation outcomeof "Deficient" and reported in the database as described in Section 2.3 of thisGuidance.

Any building previously evaluated to criteria substantially less stringent than the minimumevaluation requirements in ICSSC RP4 cannot be considered as having met the evaluationrequirements described in Section 3.2. These buildings should be considered as un­evaluated buildings.

Many previously evaluated buildings are likely to be categorized as "exceptionally highrisk." Agencies should report the information from those buildings as such. Agencies areencouraged to include previously evaluated buildings which are not "exceptionally highrisk" buildings as part of their representative sample of remaining non-exempt buildingsin order to utilize available data as much as possible.

3.2 Performing Evaluations on Selected Buildings

The minimum evaluation procedure to be used is the preliminary evaluation (checklist procedure)described in ICSSC RP4. The detailed evaluation may be used if the building fails thepreliminary checklist in an attempt to more precisely differentiate between the potential hazardsidentified in the preliminary procedure and true hazards needing rehabilitative action. Agency­specific evaluation procedures may be used as long as they meet or exceed the procedures inICSSC RP4. Such procedures are to be summarized in the supporting documentation.

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If the JCSSC RP4 procedure is used, the expected ground acceleration determined from the mapsthat are cited in JCSSe RP4 shall be considered a minimum allowable value for use in theevaluation. Acceleration values from other sources may be used if they are not lower than the

.JeSSe RP4 values. However, acceleration values from site specific studies may be used evenif they are lower than JCSSe RP4 values.

For buildings requiring higher than life safety performance, each agency should use evaluationcriteria and hazard maps deemed most appropriate by agency. The standards and proceduresused shall be reported in the accompanying documentation.

3.2.1 Goal of Evaluation

For each evaluated building, the goal is to determine and report (in the inventory database)whether the building is OK (provides adequate seismic safety as is) or Deficient (does notprovide adequate seismic safety).

For buildings judged Deficient, the cause of the deficiency is also to be noted andreported. Causes of deficiency include:

- structural deficiency- nonstructural deficiency- geologiclsite hazard is unacceptable- adjacency problems- combination of above reasons- DNR (definitely needing rehabilitation) category (see Section 3.2.2 below)

For buildings judged Deficient, an estimated cost of rehabilitation is to be calculated andreported (see Section 4 of this document).

3.2.2 DNR (Definitely Needing Rehabilitation) Buildings

There is no need to perform an engineering evaluation for those buildings selected forevaluation that can be readily identified as definitely needing rehabilitation (DNR) in theopinion of the owning agency. These buildings may be deemed Deficient without furtherevaluation. An estimated cost of rehabilitation is to be calculated and reported.

Suggested categories of DNR include:- unreinforced masonry buildings in areas of high seismicity- concrete frame buildings without shear walls built before 1960 in areas of high

seismicity- pre-cast frame buildings in moderate and high seismic zones

Agencies may identify buildings with certain other characteristics which they deem to beDNR buildings. The rationale used to develop additional agency-specific DNR definitionsmust be based on documented performance of the structural system, in either laboratorytests or actual earthquakes. Any such definitions must be summarized in the writtensupporting documentation.

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"

4.0 ESTIMATING COST OF REHABll..ITAnON

The Interagency Committee on Seismic Safety in Construction (ICSSC) recommended proceduresfor estimating costs of rehabilitation are as follows.

4.1 Cost Estimates for Evaluated and Deficient Buildings

For each evaluated building found to be deficient, the following categories of cost are to becalculated and separately reported in the inventory database:

- structural (changes to the lateral force resisting system)- nonstructural (changes to other parts of the building and to building equipment,

systems, and contents)- finishing (costs of removing and replacing fmishes such as wallboard, paint,

carpet, etc.)- project costs (design, testing, and permit fees, cost of project management, etc.)

Costs of other upgrades triggered by the rehabilitation effort (such as handicapped access,asbestos removal, etc.) are not to be included. Details on what is and is not included in eachof the cost components are given in the Handbook.

Acceptable cost estimation methods include the following:

a. Have the evaluating engineer develop a preliminary rehabilitation scheme appropriate forthe specific structure, not less stringent than the ICSSC RP4 life safety criteria, andcalculate the cost of the proposed fix. (Note, for this cost estimation method, the agencymay use any nationally accepted seismic hazard map or available site-specific study as thesource of ground acceleration values. No specific map is mandated for use.)

b. Use agency-specific cost estimating procedures. Include detailed information on theprocedure used in supporting information that is submitted-.

c. Use the default method: Follow cost estimating Option II in Seqond Edition - Typical Costsfor Seismic Rehabilitation ofExisting Buildings, Volume I [FEMA 156, 1994] to calculatestructural costs. Use procedures outlined in Volume II of Second Edition - Typical Costs[FEMA 157, 1995] to calculate nonstructural, finishing, and project costs.

d. If, instead of being rehabilitated, the building would be replaced, a replacement costshould be reported instead of a rehabilitation cost, and so noted ..

e. If, instead of being rehabilitated, the building would be abandoned and not replaced, thereported rehabilitation cost should be the cost of disposal. If no disposal cost is'anticipated, the rehabilitation cost can be reported as zero.

4.2 Cost Estimates for Non-Evaluated Buildings

Agencies are to develop an estimate of the cost of achieving adequate seismic safety for thosenon-exempt buildings that were not evaluated, where it is expected that rehabilitation will berequired. Each of the four sub-categories of cost defined in Section 4.1 are to be developed andreported.

In developing this estimate, agencies should use the vulnerability and cost data collected in non-

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exempt evaluated buildings to estimate the vulnerability and cost for non-exempt non-evaluatedbuildings. Agencies should address, at a minimum, the following considerations:

a. The proportion of buildings found to be Deficient in the evaluated buildings will likely begreater than the proportion of Deficient buildings in the non-evaluated population. Thisis because all "exceptionally high risk" buildings should have been identified andevaluated; a significant proportion of these will likely be found Deficient. A rationalprocedure for estimating the proportion of Deficient buildings in the non-evaluatedpopulation, taking this imbalance into account, is to be used and described in thesupporting documentation.

b. The proportion of non-evaluated buildings found to be Deficient in regions of lowseismicity may be different from proportions in regions of moderate or high seismicity.A rational procedure for accounting for these differences is to be used and reported in thesupporting documentation. Differences and similarities in outcomes of evaluations forsimilar building types in regions of high and moderate seismicity should be examined toidentify whether trends can be rationally extrapolated to regions of low seismicity.

c. Existing studies (such as Second Edition - Typical Costs) have shown that rehabilitationcosts for essential buildings exceed costs for non-essential buildings. Similarly,rehabilitation costs for historic buildings typically exceed costs for non-historic buildings.Estimated rehabilitation costs for these subcategories of non-evaluated buildings (essentialand historic) should be calculated separately from estimates for other building types.

d. Cost estimates for non-evaluated buildings should be based on the 15 model building types(specified in Section 2.3) that represent at least 85 percent of the non-exempt, non­evaluated building stock in regions of moderate and high seismicity.

The cost estimate for rehabilitating the number of Deficient, non-exempt, non-evaluatedbuildings should be developed and presented in tabular form by three major categories ofbuildings (Essential, Historic, and All Others), arranged by three areas of seismicity (high,moderate, and low). Further, the All Others category should be arrayed by the 15 modelbuilding types that represent at least 85 % of the non-exempt, non-evaluated building stock inregions of high and moderate seismcity for each agency. (See the Handbook for details ofappropriate format for reporting.) .

The cost estimate should, for each of the building categories prescribed above, indicate both thenumber of non-evaluated buildings expected to be found Deficient and the expected total areain square meters these buildings represent. Costs in each of the four cost categories, discussedin Section 4.1, are to be reported in both costs per square meter and total cost for the expectedpopulation.

A detailed explanation should be provided on the estimating methodology that was employed.Because a building-by-building cost estimate will not be developed for the non-evaluatedbuildings, the information on cost of rehabilitating Deficient, non-exempt, non-evaluatedbuildings is to be reported in the supporting documentation, rather than in the inventorydatabase.

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5.0 REPORTING REQUIREMENTS

The infonnation collected must be submitted to the Federal Emergency Management Agency(FEMA) no later than Dec. 1, 1998. Earlier submissions will be welcomed. Early submissionof portions of the owned building database will be particularly helpful in establishing efficientprocedures for transmitting data. Suggested milestones that are appropriate for early submissioninclude:

1. Completion of screening for exempt/non-exempt status.2. Completion of identification of "exceptionally high risk" buildings.3. Completion of identification of representative sample of remaining non-exempt

buildings.4. Completion of evaluations.

If early, partial submissions are made, the agency is asked to resubmit the entire database whenit is complete (no later than December 1, 1998).

The reporting requirements are as follows.

5.1 Contents and fonnat of the submission

The submission shall include two databases in electronic form and supporting writtendocumentation. A detailed fonnat for submissions is given in the Handbook.

5.1.1 DatabasesTwo databases are to be submitted.1. Database of leased buildings: a duplicate of the agency submission to the General

Services Administration (GSA) for real property inventory purposes is acceptable,or any other current agency leased-property database.

2. Database of owned buildings: all owned buildings are to be included. Each buildingis to be identified as either exempt; non-exempt, not evaluated; or non-exempt,evaluated. See Section 2.3 and Table A for the list of characteristics that must bereported in each of the three categories. The Handbook gives detailed definitionsfor each of the characteristics, and formatting requirements for the database(number, order and size of fields, codes to be used, etc.)

5.1.21.

2.

·3.

4.

5.

6.

Supporting written documentationDescribe any assumptions made during the exemption process; specifybenchmark years used.Describe criteria and methodology used to identify "exceptionally high risk"buildings.Describe categories considered and selection procedures used to designatebuildings for evaluation in the representative sampie of non-exempt buildings.Summarize agency-specific seismic evaluation criteria used for life-safetyevaluations if it differs from the IeSSe RP4 minimum procedure.Describe criteria used for evaluation of buildings requiring higher than lifesafety.Describe any agency-specific DNR (definitely needing rehabilitation) categoriesused.

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7. Report the cost of performing the evaluations.8. Describe any agency-specific cost estimating methods used for developing

building-by-building cost estimates.9. Describe methods used for estimating rehabilitation costs for non-evaluated

buildings.10. Report estimated cost of achieving adequate seismic safety in non-evaluated

buildings, by Essential, Historic, and All Others categories, the latter arrayed bythe 15 building types specified in Section 2.3, by square meter, and in total.

11. Submit an estimated average annual attrition rate (rate at which existing ownedbuildings are removed from the inventory for any reason).

12. Estimate the cost impact of reducing seismic risk in leased buildings. If aprogram other than that recommended in JCSSC RP4 (allowing existing leasesto expire without action, and not entering into new leases in inadequate space)will be used, describe the program.

5.2 Corrections to Submitted Databases

Agencies will be asked to correct and re-submit entire databases or individual database entriesthat are not consistent with the prescribed reporting format, as described in the Handbook, orthat present unintelligible data.

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6.0 REFERENCES

Bieniawski, A. and D. Todd, How-To Suggestions for Implementing Executive Order 12941 onSeismic Safety ofExisting Federal Buildings, A Handbook, (under preparation, publicationexpected December 1995), National Institute of Standards and Technology, Gaithersburg,MD.

Building Seismic Safety Council (1995). NEHRP Recommended Provisions for the Developmentof Seismic Regulations for New Buildings, Provisions and Commentary, 1994 edition,FEMA 222A & 223A, Federal Emergency Management Agency, Washington, DC, 1995.

Building Seismic Safety Council (1992), NEHRP Recommended Provisions for the Developmentof Seismic Regulations for New Buildings, Provisions and Commentary, 1991 edition,FEMA 222 & 223, Federal Emergency Management Agency, Washington, DC, 1992..

Building Seismic Safety Council (1992). NEHRP Handbook for the Seismic Evaluation ofExisting Buildings, FEMA 178, Federal Emergency Management Agency, Washington,DC, 1992.

Federal Emergency Management Agency (1994). Second Edition Typical Costs for SeismicRehabilitation ofExisting Buildings, Volume 1 - Summary, FEMA 156, December, 1994.

Federal Emergency Management Agency (1995). Second Edition Typical Costs for SeismicRehabilitation ofExisting Buildings, Volume II - Supporting Documentation, FEMA 157,October, 1995.

Interagency Committee on Seismic Safety in Construction (1994). Standards ofSeismic Safetyfor Existing Federally Owned or Leased Buildings, NISTIR 5382. Report developed by theInteragency Committee on Seismic Safety in Construction, Recommended Practice 4,ICSSC RP4, D. Todd, editor. National Institute of Standards and Technology,Gaithersburg, MD, February, 1994.

Interagency Committee on Seismic Safety in Construction (1992). Guidelines and Proceduresfor Implementation ofthe Executive Order on Seismic Safety ofNew Building Construction,NlSTIR 4852. Report developed by the Interagency Committee on Seismic Safety inConstruction, Recommended Practice 2.1-a, ICSSe RP2.1-A, D. Todd and A. Bieniawski,editors, National Institute of Standards and Technology, Gaithersburg, MD, 1992.

Public Law 101-614, The National Earthquake Hazards Reduction Program (NEHRP)Reauthorization Act of 1990, 104 STAT. 3231, November, 1990.

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APPENDIX A

Text of Executive Order 12941

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.~ ,J •

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Federal Register

Vol. 59. No. 232.

Monday. December 5. 1994

Title 3-

The President

62545

Presidential Documents

Executive Order 12941 of December 1, 1994

Seismic Safety of Existing Federally Owned or Leased Build­ings

By the authority vested in me as President by the Constitution and thelaws of the {Tnited States of America, and in furtherance of the EarthquakeHazards Reduction Act of 1977, as amended by Public Law 101-614, whichrequires the President to adopt "standards for assessing "nd enhancing theseismic safety of existing buildings constructed for or leased by the FederalGovernment which were desigr:ed and constructed without adequate seismicde;~ign and construction standcrds" (42 U.S.c. 770Sb(a)), it is hereby orderedas iollows:

Section 1. Adoption of Minimum Standards. The Standards of Seismic Safetyfor Existing Federally Owned or Leased Buildings (Standards). developed,issued, and maintained by the Interagency Committee on Seismic Safetyin Construction (ICSSC), are hereby adopted as the minimum level acceptablefor use by Federal departments and agencies in assessing the seismic safetyof their owned and leased buildings and in mitigating unacceptable seismicrisks in those buildings. The Standards shall be applied, at a minimum,to those buildings identified in the Standards as requiring evaluation and,if necessaty, mitigation. Evaluations and mitigations that were completedprior to the date of this order under agency programs that were basedon standards deemed adequate and appropriate by. the individual agencyneed not be reconsidered unless othenvise stipulated .by· .the Standards.

For the purposes of this order, buildings are defined as any structure,fully or partially enclosed, located within the United States as definedin the Earthquake Hazards Reduction Act of 1977, as amended, (42 U.S.C.7703(5)), used or intended for sheltering persons or property, except forthe exclusions specified in the Standards.Sec. 2. Estimating Costs of Mitigation. Each agency that owns or leasesbuildings for Federal use shall, within 4 years of the issuance of this order,develop an inventory of their owned and leased buildings and shall estimatethe costs of mitigating unacceptable seismic risks in those buildings. Thecost estimate shall be based on the exemptions and evaluation and mitigationrequirements iL the Standards. Guidance for the development of the inventoryand cost estimates will be issued by the ICSSC no later than 1 year afterthe' signing of this order. Cost estimates with supportlng documentationshall be submitted to the Director of the Federal Emergency ManagementAgency (FEMA) no later than 4 years after the signing of this order.

Sec. 3. Implementation Responsibilities. (a) The Federal Emergency Manage­ment Agency is responsible for (1) notifying all Federal departments a!\.1cogencies of the· existence a:!,j C):,tcnt of this order; (2) preparing for theCongress, in consultCltion with tile ICSSC. no later than 6 years after theissuance of this order, a comprehensive report on how to achieve an adequatelevel of seismic safety in federally owned and leased buildings ir; an economi­cally feasible manner; and (3) preparing for the Congress on t1 biennialbasis, a report on the executiun ()f this ordui.

(b) The National Institute of Standards and Tecl1l1ology is responsiblefor providing technical aSSiSl2!lCe to the F·~der21 departments and agenciesin the implementation of this orcL;r,

(c) .Federal dep8rtmunts and c,gencies lllay iequest an exempuon fron!this order from the Director of the Office of \ !2!:i'gelT'.cnt 2nd Buc:g'".'t.

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~254'6 Federal Register I Vol. 59, No. 232 / Monday. Decembe~ 5, 1994 I Presidential Docume·nts.

Sec. 4. lUpdating Programs. The rcssc shall update the Standards at leastevery 5 years. It shall also l..:?daJe the Standards within 2 years 'Of ,thepublication of the first edition of FEMA's Guidelines for Seismic Rehabilita-tion of Buildings and Commentc;-:.. .

Sec. 5. Judicial Revj(;;·... Nothi"g in this order, is intended to create any:right "to 'administrative or i:judicial crev.-iew. or any other right. benefit. ;ortrust resronsibility. substantive or procedural, enforceable at law 'by any

,parlyiagainst the United 61alBS. ·it.s~encies·or instrumentalities..Jls!officersor employees, or any person.

THE \'VHITE HOUSE,December 1. 1994.

WH DQC- 9';-300)~

F:!(,{~ 12-2-~14: 9:2G ",,,!r~il"c.?- endc ~195-01-P